T2 Adjustment Case Studies

6 worked T2 Adjustment case studies — the position a client typically comes to us with, what we do, and what it is worth. Each is an illustrative example built on the rules that apply to t2 adjustment work, not a specific client's file.

Case Study 1 · Missed incentive claimed

$119,000 Credit Claim Filed And Accepted Without Adjustment — Corporate Rental Portfolio, Saskatoon

Client: A corporately-owned rental portfolio  ·  Where: Saskatoon, Saskatchewan  ·  Engagement: 3 weeks, fixed fee

Claim value$119,000
AcceptedWithout adjustment
RepeatableAnnually

The situation — A corporately-owned rental portfolio, Saskatoon, Saskatchewan

A corporately-owned rental portfolio in Saskatoon, Saskatchewan assumed the credits did not apply to a business its size. Retained earnings building in the operating company with no plan for extracting them meant they had applied all along.

What we did for A corporately-owned rental portfolio, Saskatoon, Saskatchewan

We identified the qualifying activity, built the documentation to support it, and mapped the association rules across the group, allocated the business limit deliberately on Schedule 23, and corrected the prior year by adjustment request.

The result — A corporately-owned rental portfolio, Saskatoon, Saskatchewan

$119,000 recovered. Because the eligibility analysis is on file, the same claim can be repeated each year with a fraction of the effort.

Case Study 2 · Records and systems rebuilt

Month-End Close Cut From 12 Weeks To 8 Days — Non-Calendar Year-End Corporation, Barrie

Client: A corporation with a non-calendar fiscal year-end  ·  Where: Barrie, Ontario  ·  Engagement: 3 weeks, fixed fee

Close time before12 weeks
Close time after8 days
Year-endReview, not rebuild

The situation — A corporation with a non-calendar fiscal year-end, Barrie, Ontario

The accounting file at a corporation with a non-calendar fiscal year-end in Barrie, Ontario was built on a loss year carried forward by default when carrying it back would have produced a refund cheque. The year-end had taken 12 weeks each of the last three years.

What we did for A corporation with a non-calendar fiscal year-end, Barrie, Ontario

We reviewed each capital cost allowance pool and set the claim at the level that kept the small business deduction fully used rather than wasted and moved the reconciliations into the monthly cycle, so the year-end stopped being a rebuild.

The result — A corporation with a non-calendar fiscal year-end, Barrie, Ontario

The file reconciles. Month-end closes in 8 days instead of 12 weeks, and the year-end is a review rather than a reconstruction.

Case Study 3 · Sale and succession

$480,000 Sheltered By The Lifetime Capital Gains Exemption — First-Profit Technology CCPC, Winnipeg

Client: A technology CCPC approaching its first profitable year  ·  Where: Winnipeg, Manitoba  ·  Engagement: 11 weeks, fixed fee

Gain sheltered$480,000
ClosingOn schedule
Share qualificationMet

The situation — A technology CCPC approaching its first profitable year, Winnipeg, Manitoba

A technology CCPC approaching its first profitable year in Winnipeg, Manitoba had an offer on the table and 32 months to close. The shares did not qualify for the capital gains exemption, and no valuation on file to support the price the parties had agreed was part of the reason.

What we did for A technology CCPC approaching its first profitable year, Winnipeg, Manitoba

We purified the corporation so the shares met the qualifying tests, then documented safe income before the inter-corporate dividend was paid, so subsection 55(2) had no room to recharacterise it as a gain well ahead of the closing date.

The result — A technology CCPC approaching its first profitable year, Winnipeg, Manitoba

The sale closed on schedule with $480,000 sheltered by the lifetime capital gains exemption across the shareholders.

Case Study 4 · Cash and remittance control

Remittance Schedule Corrected, $147,000 Refunded — Two-Shareholder CCPC, Red Deer

Client: A CCPC with two shareholders  ·  Where: Red Deer, Alberta  ·  Engagement: 6 weeks, fixed fee

Overpayment refunded$147,000
Late remittances sinceZero
ScheduleAutomated

The situation — A CCPC with two shareholders, Red Deer, Alberta

Remittances at a CCPC with two shareholders in Red Deer, Alberta were consistently late by a few days, which was enough to trigger penalties every quarter. Behind it sat dividends moved up to a holding company year after year with no safe-income support on file.

What we did for A CCPC with two shareholders, Red Deer, Alberta

We reconstructed the capital dividend account from the underlying transactions and filed the subsection 83(2) election before the next distribution left the company, then moved the remittance dates into a scheduled process rather than a monthly decision.

The result — A CCPC with two shareholders, Red Deer, Alberta

Penalties stopped from the following remittance onwards, and $147,000 of overpaid instalments was refunded.

Case Study 5 · Backlog brought current

$41,000 Of Arbitrary Assessments Vacated After 4 Years — Incorporated Trades Business, Vancouver

Client: An incorporated trades business  ·  Where: Vancouver, British Columbia  ·  Engagement: 9 weeks, fixed fee

Arbitrary tax vacated$41,000
Years brought current4
Account statusCurrent

The situation — An incorporated trades business, Vancouver, British Columbia

4 years of unfiled returns had turned into notional assessments at an incorporated trades business in Vancouver, British Columbia, with retained earnings building in the operating company with no plan for extracting them underneath. Collections had already started.

What we did for An incorporated trades business, Vancouver, British Columbia

We carried the non-capital loss back against the two profitable years and recovered tax already paid instead of holding a carry-forward balance, then filed every outstanding year in chronological order so the CRA could vacate the notional assessments cleanly.

The result — An incorporated trades business, Vancouver, British Columbia

All 4 years were accepted as filed. $41,000 of arbitrarily assessed tax was vacated, collections action stopped, and the account is current for the first time in 4 years.

Case Study 6 · Planning that cut the bill

$49,000 Saved By Correcting What Prior Filings Had Missed — Holding and Operating Companies, Burnaby

Client: A holding company and its operating subsidiary  ·  Where: Burnaby, British Columbia  ·  Engagement: 7 weeks, fixed fee

Saving identified$49,000
RecurringYes
Positions documentedAll

The situation — A holding company and its operating subsidiary, Burnaby, British Columbia

A holding company and its operating subsidiary in Burnaby, British Columbia asked for a second opinion on t2 adjustment after three years of rising tax. The review found passive investment income that had crossed the $50,000 grind threshold unnoticed.

What we did for A holding company and its operating subsidiary, Burnaby, British Columbia

We built the comparison first — current structure against two alternatives — and then modelled salary against dividends across both the corporation and the shareholder’s personal return, then set the remuneration mix for the year.

The result — A holding company and its operating subsidiary, Burnaby, British Columbia

First-year saving of $49,000, with the same benefit recurring. Every position taken is documented and supported in the file.

Reviewed for the 2025 tax year by Udit Gupta, Founder and Tax Accountant. These case studies are illustrative worked examples composed from the CRA rules that apply to this type of work, not specific client files; figures are representative and outcomes depend on your own facts.

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